B. Training Activities

1. Number of trainings presented by PAIR staff

13

2. Number of individuals who attended training (approximate)

887

The P&A presented at thirteen (13) conferences where eight hundred eighty-seven (887) individuals were trained using the lecture method, with handouts for training on rights regarding employment, emergency and disaster awareness training and educational rights. Trainings included question and answer periods for each topic. Educational rights topics including PBIS, restraint and seclusion, transition to employment and community living, prevention of drop outs, learning disabilities, and etc. for students in public schools, their parents, therapists, teachers, attorneys, case managers (DHS, OJA), Native American providers and judges.

The purpose of the trainings was to educate the participants about their rights and how to enforce them.

Also, not included in the total number were thirteen (13) booths at various statewide conferences where ODLC handed out information about the P&A and information regarding the conference topics (i.e. education). It is estimated that one thousand and twenty-six (1,026) people came to booths.

C. Information Disseminated to the Public

1. Radio and TV appearances by PAIR staff

1

2. Newspaper/magazine/journal articles

0

3. PSAs/videos aired

0

4. Hits on the PAIR/P&A website

14,112

5. Publications/booklets/brochures disseminated

1,774

6. Other (specify separately)

2

Narrative

WEBSITES:

http://www.okdlc.org

SOCIAL MEDIA:

Facebook: OK Disability Law Center, Inc.

Twitter: @okdlc

3,456 individuals were reached by these social media accounts

Part II. Individuals Served

A. Individuals Served

Count individual once per FY. Multiple counts not permitted for lines A1 through A3.

1. Individuals still served as of October 1 (carryover from prior FY)

16

2. Additional individuals served during the year

34

3. Total individuals served (lines A1 + A2)

50

4. Individuals w. more than 1 case opened/closed during the FY. (Do not add this number to total on line A3 above.)

E. Intervention Strategies Used in Serving Individuals

List the highest level of intervention used by PAIR prior to closing each case file.

1. Technical assistance in self-advocacy

0

2. Short-term assistance

12

3. Investigation/monitoring

3

4. Negotiation

13

5. Mediation/alternative dispute resolution

2

6. Administrative hearings

0

7. Litigation (including class actions)

0

8. Systemic/policy activities

1

Part III. Statistical Information on Individuals Served

A. Age of Individuals Served as of October 1

Multiple responses not permitted.

1. 0 - 4

0

2. 5 - 22

6

3. 23 - 59

29

4. 60 - 64

7

5. 65 and over

8

B. Gender of Individuals Served

Multiple responses not permitted.

1. Females

21

2. Males

29

C. Race/Ethnicity of Individuals Served

1. Hispanic/Latino of any race

2

For individuals who are non-Hispanic/Latino only

2. American Indian or Alaskan Native

2

3. Asian

0

4. Black or African American

13

5. Native Hawaiian or Other Pacific Islander

0

6. White

33

7. Two or more races

0

8. Race/ethnicity unknown

0

D. Living Arrangements of Individuals Served

Multiple responses not permitted.

1. Independent

15

2. Parental or other family home

7

3. Community residential home

0

4. Foster care

0

5. Nursing home

1

6. Public institutional living arrangement

0

7. Private institutional living arrangement

0

8. Jail/prison/detention center

27

9. Homeless

0

10. Other living arrangements

0

11. Living arrangements not known

0

E. Primary Disability of Individuals Served

Identify the individual's primary disability, namely the one directly related to the issues/complaints

1. Blind/visual impairment

0

2. Deaf/hard of hearing

2

3. Deaf-blind

0

4. Orthopedic impairment

20

5. Mental illness

7

6. Substance abuse

0

7. Mental retardation

0

8. Learning disability

1

9. Neurological impairment

6

10. Respiratory impairment

2

11. Heart/other circulatory impairment

5

12. Muscular/skeletal impairment

2

13. Speech impairment

0

14. AIDS/HIV

0

15. Traumatic brain injury

0

16. Other disability

5

Part IV. Systemic Activities and Litigation

A. Systemic Activities

1. Number of policies/practices changed as a result of non-litigation systemic activities

5

2. Number of individuals potentially impacted by policy changes

23,370

Describe your systemic activities. Be sure to include information about the policies that were changed and how these changes benefit individuals with disabilities. Include case examples of how your systemic activities impacted individuals served.

MONITORING STATE PRISONS: The P&A has increased its monitoring presence in the Oklahoma Prison System. This year, the P&A has monitored three prisons thereby increasing its outreach to this underserved population. Due to this outreach, the P&A has seen a large increase in the number of prisoners contacting our office for service. During this FY, the P&A opened a systemic investigation regarding the lack of medical, mental health and dental care at Lawton Correctional Facility, the largest private prison in Oklahoma. The investigation will continue into FY 2018.

SCHOOL TO PRISON PIPELINE: In late September of 2016, staff from the P&A, in partnership with staff from the Oklahoma Department of Human Services, Oklahoma Juvenile Affairs and the Oklahoma Supreme Court, attended Georgetown University’s Center for Juvenile Justice Reform’s certificate program focusing on School-Justice Partnership and submitted a capstone project focusing on children “in care”, that are currently under state court supervision.

The overarching goals of this systemic capstone project are to enhance educational outcomes for children with special needs in the delinquent system (including children with serious mental illness and developmental disabilities) and reduce the school to prison pipeline. Currently, there are 10,156 in either foster care, or out of home placement. 33% (3,351) of those children have been identified as having either serious mental illness, physical disabilities or developmental delays.

The capstone is a two-part project. The first part is educating the Judiciary and the second part is educating the Oklahoma Juvenile Court Stakeholders. Below is a description of the project and outcomes during FY 2016.

1. Education of the Judiciary and Court staff to equip Oklahoma Juvenile Courts with the necessary tools to address certain federal claims arising out of state placement of children and youth in care.

Children with mental or developmental disabilities in the custody of New Mexico brought a court action alleging that state officers had failed to provide protections and therapeutic services required by federal statutes and the Constitution. The United States District Court in New Mexico denied class certification and abstained from hearing the case. The Tenth Circuit affirmed and said, among other things, that abstention was justified.

The Tenth Circuit concluded that federal courts on rare occasions must abstain from exercising their jurisdiction in order to "avoid undue interference with states' conduct of their own affairs." They cited U. S. Supreme Court cases resting on "a strong federal policy against federal-court interference with pending state judicial proceedings absent extraordinary circumstances." The Tenth Circuit followed the Younger doctrine which requires abstention when federal proceedings would (1) interfere with an ongoing state judicial proceeding (2) that implicates important state interests and (3) that affords an adequate opportunity to raise the federal claims.

The court agreed to abstain provided that the children’s court was exercising continuing jurisdiction and no statutory directive precluded or impaired the court’s jurisdiction. In other words, so long as the Oklahoma judges hearing juvenile cases will hear and render judgment on federal rights assured to children with both mental and physical disabilities in state custody or under state court supervision, the federal court is compelled, without discretion, to abstain.

Issues to be addressed in trainings:

A. Criminalizing Students with mental and physical disabilities when the disability is a factor in the action giving rise to the “crime.”

B. Children in Group Homes - whether children in group homes and children transitioning out of psychiatric or residential treatment facilities are educated in the LRE and receiving FAPE.

C. Literacy - Oklahoma does not have research based methods to address dyslexia, a disability affecting approximately 20% of the population. Students not reading at his or her grade level by the end of the third grade arefour times less likely to graduatehigh school on time-six times less likely for students from low-income families. In a2009 studyby researchers at Northwestern University, it was found that high school dropouts were 63 times more likely to be incarcerated than college graduates.

D. Child-find: Court staff are unaware of how to identify students in need.

2. Education of all other Juvenile Court Stakeholders, including but not limited to: municipal attorneys, foster parents, education advocate, child welfare workers, juvenile attorneys, and others with a desire to learn more about the laws that apply to children in our juvenile court with physical and mental disabilities. The same issues will be addressed as listed above.

Outcomes:

On October 12 and 13, 2016, the team successfully implemented the first phase of its training for stakeholders. Members of the Oklahoma Team collaborated with a number of stakeholders to cultivate an educational conference to be hosted in two of Oklahoma’s largest cities. The conference, titled “Enhancing Educational Success for Children and Youth in Care,” was held in- Tulsa, Oklahoma on October 12, 2016 and Oklahoma City on October 13, 2016. The Conference article can be found here:

Approximately, 262 individuals were registered for this the two conferences. Child welfare specialist from the Oklahoma Department of Human Services, child advocates, attorneys, educators, foster care parents, and a member of the judiciary were in attendance. Pre and post conference surveys were taken. The post conference results can be found at the following links:

Tulsa https://www.surveymonkey.com/results/SM-BGJ928VN/;

Oklahoma City https://www.surveymonkey.com/results/SM-SS3S6KVN/.

The P&A hosted a Wrightslaw Special Education Conference on December 8, 2016 as a part of this project with 200 Attendees. Attendees included biological parents, foster parents, DHS Caseworkers, OJA workers, attorneys and Judges.

Additionally, two members of the capstone project team (one from the Oklahoma Department of Human Services and one from the Office of Juvenile Affairs) were able to work on Senate Bill (SB) 632- legislation that address the educational needs of children in state custody. The legislation titled the "Education Compact for Students in State Care Act” created the Education Compact for Kids in State Care Advisory Committee. The DHS and OJA members from our team, along with other State Agencies will set on this Advisory Committee. At the end of October, 2017 the Committee will send out a memo to all school superintendents advising them about SB 632 and its requirements for school districts.

The capstone is an ongoing project and three trainings are currently planned for FY 2018.

EMERGENCY PREPAREDNESS: In FY 2017, the P&A continued its relationship with the Oklahoma Department of Health and their emergency preparedness efforts in developing a statewide trainings agencies providing care during and after disasters. The P&A continues to be a part of the FAST (Functional Assessment Support Team).

The P&A provided training at the regional Medical Reserve Corp (MRC) conference and two trainings at the Oklahoma Emergency Managers Conference, training State, County and City Emergency Managers in August, 2017. The P&A presented information regarding legal obligations under the Americans with Disabilities Act.

FACILITIES OUTREACH: The P&A continues to visit residential facilities where people who are eligible for PAIR live to assure that PAIR eligible clients are aware of their rights where they live and are free from abuse and neglect.

TRIBAL TRAINING AND OUTREACH: During FY 2017, the P&A continued its collaboration with the tribal community and regional training on legal rights and their enforcement.

B. Litigation/Class Actions

1. Number of individuals potentially impacted by changes as a result of PAIR litigation/class action efforts

0

2. Number of individuals named in class actions

0

Describe your litigation/class action activities. Explain how individuals with disabilities benefited from your litigation activities. Be sure to include case examples that demonstrate the impact of your litigation.

N/A

Part V. PAIR'S Priorities and Objectives

A. Priorities and Objectives for the Fiscal Year Covered by this Report

For each of your PAIR program priorities for the fiscal year covered by this report, please:

Identify and describe priority.

Identify the need, issue or barrier addressed by this priority.

Identify and describe indicators PAIR used to determine successful outcome of activities pursued under this priority.

Explain whether pursuing this priority involved collaborative efforts by other entities. If so, describe this collaboration.

Provide the number of cases handled under the priority. Indicate how many of these, if any, were class actions.

Provide at least one case summary that demonstrates the impact of the priority.

NEED TO BE ADDRESSED: Need to live productive lives free of discrimination based on disability

DESCRIPTION OF ACTIVITIES TO BE CARRIED OUT UNDER PRIORITY: provide representation to enforce anti-discrimination statutes, including education; coordinate complaints with federal and state agencies that enforce anti-discrimination statutes; provide representation to clients to achieve income and medical benefits or referral to appropriate, available attorneys; provide representation to clients who face systemic, physical barriers and exclusion based on disability; provide legal advice and counseling to develop and implement self-advocacy for individuals with disabilities, including maintenance of websites, listservs and social media; improve skills for mediation and other remedies to promote inclusion in the least restrictive environment

CASE SUMMARY:

A person saw staff from the P&A on the news doing an interview about the rights of people with disabilities regarding accessible parking, and called the P&A about a systemic issue concerning parking in the City of Bethany. The client explained she frequently visited businesses located on 39th Expressway and that she experienced great difficulty with access to the businesses due to her use of a walker and cane.

P&A staff went to Bethany and took pictures of the areas of concern. They found there were 38 parking spots in the particular area of concern. The spots sat at a slight angle and faced the buildings. There was a small divider in the middle with 19 spots on either side. After researching the Americans with Disabilities Act (ADA) regulations, the P&A determined there should be at least 2 spots designated as Accessible Parking with at least one of those being a designated Van Accessible spot.

The P&A contacted the Bethany City Manager and filed a complaint, raising these issues:

1. Accessible (Handicap) Parking Spots: There were no markings on the ground to designate which spots were the accessible spots and all lines were the same color (white). This, along with the following issues made it very difficult to determine which spots were actually designated as accessible.

The accessible parking signs were posted on the line between spots so it was hard to tell how many spots were designated as accessible spots. All accessible spots were located between the middle divider and the corner of Asbury, no accessible signs were located to the East of the divider. There were two signs posted, one on the line dividing the two spots immediately to the West of the middle divider and one on the line dividing the two spots immediately to the East of the corner of 39th Expressway and Asbury. All parking spots appeared to be the same size and appeared narrow. None of the spots were marked as “Van Accessible” and there were no access isles to allow space to maneuver a wheelchair, walker or other mobility device to the curb cuts.

2. Curb Cuts: There were two curb cuts adjacent to the parking area. The curb cuts opened directly into parking spots and did not have access isles connected to them. They could not be accessed if a car was parked in the spot next to the curb cut.

There was also a curb cut on the corner of 39th Expressway and College, opening onto College and one on the corner of 39th Expressway and Asbury, opening onto Asbury. The curb cuts located on College and Asbury could only be accessed from the street on which they were located. If cars were parked in the spots directly next to the curb cuts in the parking area, the only accessible access to the sidewalk would require a person to go into the street on 39th, continue in the street to either College or Asbury and then access a curb cut from the street. This presented various safety issues, as 39th Expressway is a very busy street.

3. Additional parking behind the buildings. At the time of the complaint, the P&A was uncertain if the lot was owned by the City or was private property. The parking area appeared to have been recently restriped and none of the parking spots were marked as designated accessible parking spots.

When the Bethany City Manager received our complaint, he was very receptive and told the P&A they would do whatever was necessary to comply with the Americans with Disabilities Act. He told the P&A that the City did own the parking lot in the back of the building and would add accessible parking spots that would be marked correctly.

The City marked seven (7) spots in the back parking lot within a month of receiving our complaint. The City had to coordinate with the Oklahoma Department of Transportation (ODOT) regarding making changes on 39th Expressway as it is considered a state highway.

Once receiving permission from ODOT, Bethany began making necessary changes to the parking and curb cuts on 39th Expressway. The first change was to the parking spot off of Asbury. The City clearly marked which spot was the accessible parking spot and added striping on the ground to indicate it was a van accessible spot. This also resolved the issue of access to the curb cut on Asbury. The City also added a handicap spot and a curb cut in the middle divider which resolved the issue of individuals having to walk down 39th street to access either the curb cut on College or Asbury.

Due to the P&A intervention, the City of Bethany took action to correct issues of parking accessibility, which allowed our client to be able to access businesses on that street in a safe manner.

STATEMENT OF PRIORITY 2: Monitor facilities, state agencies and other service providers that provide or supervise services for persons with disabilities to: eliminate abuse and neglect; improve access to appropriate services and improve quality of services

NEED TO BE ADDRESSED: Need to be free of abuse and neglect

DESCRIPTION OF ACTIVITIES TO BE CARRIED OUT UNDER PRIORITY: compliment activities of the PAIMI program to improve community mental health services in Oklahoma and the efforts of the PADD program to improve community and instutitional services for people with developmental disabilities; provide representation to residents of nursing homes and facilities to protect them from abuse and neglect and to access needed assistive technology services; coordinate with Long Term Care Ombudsman, Adult/Child Protective Services and enforcement agencies for facilities.

CASE SUMMARY:

The P&A was contacted by a family member of a prison inmate with about the medical care he was receiving while in prison. The family member expressed that due to the nature of the inmate’s disabilities and lack of medical care, she believed that he might die if our office did not intervene. The P&A contacted the Warden, the Vice President of the private prison and the General Counsel of the Oklahoma Department of Corrections explaining the following:

Our client had an ileostomy, which is an opening in the belly (abdominal wall) that’s made during surgery, with the end of the ileum (the lowest part of the small intestine) brought through this opening to form a stoma. Due to the ileostomy, he required the use of ileostomy bags. The bags stick to the skin with a disk clipped to the bag and held in place with a belt. The ileostomy bag also has a baffel which keeps urine from coming onto the stoma until the person wearing the bag releases the urine by flipping a lid.

When our client was first incarcerated with the Oklahoma Department of Corrections, we were told he was provided with ileostomy bags. However, since his arrival at the private facility, medical staff had refused to provide our client with replacement ileostomy bags and had instead, required him to use colostomy bags. Because colostomy bags are not designed for urine collection, they leaked urine and were routinely and easily dislodged. Additionally, the colostomy bags had a clip on the end that was very hard for our client to open with one hand (our client is missing four (4) fingers on his left hand).

We were told that use of colostomy bags caused him significant medical issues. For example: he had blood in his urine and a rash from the bag; his urine was milky looking, indicating he may have had an infection; his stoma was closing up, causing his urine to back up into his system; and he often had urine soaked clothing. We asked that they take immediate action to assure our client was provided appropriate medical care to prevent any further harm. His family member called the P&A back to report that our client was still struggling with the incorrect and ill-fitting bags provided to him, that he needed to keep his stoma clean and it was nearly impossible to do so with the bags provided to him by the prison; and that because he was unable to keep the area clean, it was putting him at risk for additional infections. We reported this to the prison along with these concerns: his stoma was getting smaller; he had a kidney infection due to urine backing up and that his urine was "the color of mushroom soup and burns his irritated stoma;” he had been without any medication for over a week and that his blood pressure was so high his head was pounding; our client described it as his head had a heart beat all its own; he had completed numerous “Request of Staff” to see medical personnel, for ileostomy bags and glue, and for his medications to no avail.

We again requested that the prison provide our client with necessary and appropriate medical care so his condition did not continue to deteriorate and we informed the prison that we would be coming to see our client. After this second request, and with the knowledge that these issues would be apparent to us in person, our client was almost immediately moved to a medical unit at one of the state operated prisons.

After being transferred to the state operated prison, medical personnel completed a thorough medical workup to determine the cause of our client’s medical issues. The doctor’s determined the private prison was using the incorrect type of adhesive which was causing the bags to leak resulting in the serious medical complications our client was experiencing. Because of the advocacy of the P&A our client received necessary, lifesaving medical care.

STATEMENT OF PRIORITY 3: Respond to issues and needs identified by groups who advocate on behalf of individuals with disabilities

NEED TO BE ADDRESSED: Groups identify needs of their members with disabilities and seek relief to systemic issues. Often issues arise that could not be anticipated at the time priorities and objectives were developed. The P&A will be responsive, when appropriate, to these situations, as well as continue efforts on identified systemic issues.

DESCRIPTION OF ACTIVITIES TO BE CARRIED OUT UNDER PRIORITY: The P&A will continue to participate in task forces and advisory committees on disability-related issues. The P&A will work with the federally funded parent training and information center (Oklahoma Parents Center), the Office of Disability Concerns, the P&A will continue to focus its activities on educational issues of tribal members and other organizations which focus on the concerns of their members with disabilities.

CASE SUMMARY:

Deaf Interpreters in District Court. The P&A was contacted by an organization who provides both interpreting services for deaf individuals as well as advocacy services with concerns about Oklahoma Supreme Court Administrative Directive (S.C.A.D.) 2007-32. This Directive is related to the payment of foreign language interpreters and interpreters for the deaf and hard of hearing. It states, in part “Interpreters shall be paid not to exceed Sixty Dollars ($60.00) per hour from the local court fund for actual time worked either in court or out of court. Fees shall not exceed Six Hundred Dollars ($600.00) per day. Mileage shall be paid pursuant to the State Travel Reimbursement Act.”

Oklahoma has seventy-seven (77) district courts and the P&A was told that almost all of those courts had a different interpretation of the Directive. For example, some courts lumped all interpreters together for the day, so if there was a Spanish Interpreter in one court and a Sign Language Interpreter in another court, the total that could be paid for the day was $600.00. Other Courts interpreted the Directive to mean that each of those interpreters could be paid $600.00. The organization that contacted the P&A stated that the way the Courts were interpreting the directive was preventing individuals who were deaf or hard of hearing from receiving interpreting services and thereby denying them effective communication. The organization also said they did not believe there was any system in place to request an accommodation. For example, sometimes a deaf individual required both a hearing sign language interpreter and a deaf sign language interpreter for effective communication, which would likely exceed the cap of $600.00 per day for a criminal trial.

The P&A contacted the Americans with Disabilities Act Coordinator at the Administrative Office of the Courts. This person also acts as the ADA Coordinator for all the District Courts. The P&A explained the concerns of the organization to the ADA Coordinator. The Coordinator explained that the Courts had a process for requesting accommodations to their policies and procedures, which would include requested accommodations going beyond the daily cap prescribed in S.A.C.D. 2007-32. The ADA Coordinator explained who the initial request for accommodations should be made to and that if they were unable to resolve these issues with the court, they could assist with the resolution of the request for accommodation: https://www.oscn.net/pages/accessibility.

The P&A contacted the organization that made the complaint and explained the ADA complaint system. This organization is active and well respected in the deaf community and has the ability to share this information with deaf individuals, interpreter agencies and interpreters. The P&A has not received any further complaints regarding this issue after its discussion with the ADA coordinator.

B. Priorities and Objectives for the Current Fiscal Year

Please include a statement of priorities and objectives for the current fiscal year (the fiscal year succeeding that covered by this report), which should contain the following information:

a statement of each prioirty;

the need addressed by each priority; and;

a description of the activities to be carried out under each priority.

1. Investigate allegations of abuse and neglect in the community and in institutions such as in jails, prison, and nursing homes and schools.

Need to Be Addressed: Abuse and neglect of individuals with disabilities in the community and in facilities.

A description of the activities to be carried out: Investigate allegations of abuse and neglect; Report allegations to licensing agencies and other appropriate agencies; Engage in systemic advocacy or litigation and individual representation as needed; Provide training to clients, organization and agencies on laws related to issues of abuse and neglect and our office’s authority regarding access to facilities and to investigate issues of abuse and neglect.

2. Provide representation to individuals seeking to enforce their federal and state rights regarding employment or housing discrimination, architectural accessibility, access to transportation, denial of public health benefits/health care (e.g.: Medicaid, Advantage Waiver), denial of access to private and public programs, discrimination in non-government and government benefits or services under the Americans with Disabilities Act or Section 504 of the Rehabilitation Act.

Need to Be Addressed: People with disabilities are subject to discrimination and are denied needed government and non-government services. Disability advocacy groups identify need to the P&A of their members with disabilities.

A description of the activities to be carried out: Investigate allegations of discrimination; Provide systemic advocacy or litigation and individual representation as needed to enforce federal and state laws; Provide information and advice to clients so they can engage in self-advocacy; Participate in task forces and advisory committees; Seek out disability advocacy groups to identify systemic issues that need to be identified and establish and/or maintain collaborative relationships; Collaborate with agencies providing services to individuals with disabilities such as the Long Term Care Ombudsman, Office of Disability Concerns, the Federally Funded Parent Training and Information Center (The Oklahoma Parents Center), the Client Assistance Program and the Oklahoma Department of Rehabilitation Services; Provide training to clients, organizations and agencies on laws related to people related to people with disabilities.

3. Provide representation to elementary, secondary and post-secondary students with disabilities who are subject to discrimination, reduced school day (less than 1/2 day) or denied a free appropriate public education (FAPE).

Need to Be Addressed: Students with disabilities are subjected to discrimination, denied the right to go to school all day or denied a free appropriate public education.

A description of the activities to be carried out: The P&A will seek out disability advocacy groups to identify systemic issues and establish and/or maintain collaborative relationships; Engage in systemic advocacy or litigation and individual representation as needed to address discrimination and reduced school day; Provide information and advice to clients so they can be empowered to engage in self-advocacy; Provide training to clients, organizations and agencies on laws related to students with disabilities.

Part VI. Narrative

At a minimum, you must include all of the information requested. You may include any other information, not otherwise collected on this reporting form that would be helpful in describing the extent of PAIR activities during the prior fiscal year. Please limit the narrative portion of this report, including attachments, to 20 pages or less.

The narrative should contain the following information. The instructions for this form outline the information that should be contained in each section.

Sources of funds received and expended

Budget for the fiscal year covered by this report

Description of PAIR staff (duties and person-years)

Involvement with advisory boards (if any)

Grievances filed under the grievance procedure

Coordination with the Client Assistance Program (CAP) and the State long-term care program, if these programs are not part of the P&A agency

E. Grievances: There were no grievances filed regarding the PAIR Program under the P&A written grievance procedure, which is posted on websites of the P&A and distributed to individual clients.

F: Coordination: The P&A coordinates its activities with the Client Assistance Program (CAP) by accepting referrals from the Office of Disability Concerns when those matters are not covered within the CAP responsibility and by participating jointly on systemic projects. The P&A coordinates with the State long-term care program by accepting referrals for persons who are not covered by their program and by sending them referrals of persons who are covered by their program and by working with them on the Emergency Management (FAST) training work group.